ML20217G248
| ML20217G248 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 04/23/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20217G186 | List: |
| References | |
| 50-254-98-05, 50-254-98-5, 50-265-98-05, 50-265-98-5, NUDOCS 9804290097 | |
| Download: ML20217G248 (11) | |
See also: IR 05000254/1998005
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U. S. NUCLEAR REGULATORY COMMISSION
REGION 111
Docket Nos:
50-254;50-265
License Nos:
Report No:
50-254/98005(DRS); 50-265/98005(DRS)
Licensee:
Commonwealth Edison Company (Comed)
Facility:
Quad Cities Nuclear Power Station, Units 1 and 2
Location:
22710 206th Avenue North'
Cordova, IL 61242
Dates:
February 16,1998 - March 26,1998
Inspector:
J. Guzman, Reactor inspector
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Approved by:
John Jacobson, Chief
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Lead Engineers Branch
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9804290097 900423
ADOCK 05000254
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EXECUTIVE SUMMARY
Quad Cities Nuclear Power Station, Units 1 & 2
NRC Inspection Report No. 50-254/98005(DRS); 50-265/98005(DRS)
Enaineerina
Allowances, with precautions, for development of emergency and immediate
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modifications were adequately accounted for in the Quad Cities QA Program and in
corporate and station procedures. Use of these types of modifications was not common
and, when used, adequate controls existed to ensure minimum prerequisites, limitations,
and operational restrictions were considered, including completion of 10 CFR 50.59
screenings or safety evaluations.
Adequate controls were in place to ensure that at-risk work packages developed in
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parallel with the design package would assure cornponents would not be declared
operable until completion of all design documentation. Use of the at-risk process was
not routine and work completed appeared well-coordinated between the work analyst,
design and construction staff. While generation of at-risk work packages was allowed
by the Work Request initiation procedure, at-risk work was contrary to the Plant Design
Change Process procedure. This was considered a procedural adherence violation.
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Report Details
lli. Engineering
E1
Conduct of Engineering
E1.1
Review of Emergency Modifications and At-Risk Work Process
a.
Inspection Scoce
The inspector reviewed the Quad Cities engineering modification and at-risk work
processes to ascertain compliance to the Quad Cities OA manual, as well as to
corporate and site procedures. The inspector focused on three vehicles used for
expediting design work at Quad Cities, namely (1) emergency modifications, (2) at-risk
work requests and (3) immediate modifications.
The inspector reviewed a sample of modifications developed as emergency
modifications and work packages completed using the at-risk work process. Associated
problem identification forms (PIFs) were also reviewed as were NRC commitments
related to design modifications. The inspector interviewed licensee staff cognizant with
the development of design modifications, work package preparation and work package
installation. Corporate and site procedures and other documents related to the design
change process were also reviewed including:
" Preparation and Control of Work Packages," QCAP 2200-04, Rev.17
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" Action Request / Work Request Initiation," QCAP 2200-02, Rev.12
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" Plant Design Change Process," QCAP 0460-01, Rev. 6
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" Emergency Modification to Support Appendix R," Letter dated October 28,1998
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Doc. ID: Q-ECDS-97-0613
" Engineering Requests," QCAP 0440-01, Rev.10
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" Comed QA Program Topical Report CE-1-A," Dated January 23,1998
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" Plant Modifications," NEP-04-01, Rev. 5
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b.
Observations and Findinos
b.1.
Review of OA Manual and Corocrate Procedures
The inspector reviewed licensee commitments and requirements of corporate
procedures as well as the QA manual to verify allowances related to use of (1)
emergency modifications, (2) at-risk work requests and (3) immediate modifications.
Section 3.3 of the Comed Quality Assurance Manual Quad Cities (Topical
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Report CE-1-A, dated January 23,1998) required that " design verification for the
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stage of design activity accomplished shall be performed prior to release for
procurement, manufacture, construction or release to another organization for
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use in other design activities provided sufficient data exists." The QA Manual
also added:"Any unverified portion of the design shall be identified and
controlled."
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Comed corporate procedure NEP-04-01, " Plant Modifications," Revision 5
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provided guidance on use of emergency modifications. Section 5.2.5 of this
procedure specified that "if an emergency modification is required and authorized
by Management, advanced approval may be given to start installation work. The
design supervisor shall determine the documents required to start emergency
installation work." This procedure provided minimum requirements which
included:
the specific work being authorized,
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prerequisites and limitations for the work being authorized,
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operating restrictions on the system pending completion of the
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modification, and
a completed 50.59 evaluation for the scope of work authorized by the
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advanced approval.
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Per the procedure, "the package approved by the design supervisor shall be
issued when the modification design is completed. Minimum requirements are
the design documents, the Design Change Approval and Closecut Form, and the
50.59 Safety Evaluation."
Comed corporate procedure NEP-04-01, " Plant Modifications," Revision 5,
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Section 5.2.1.21 states "If authorized by Management, at-risk changes may be
installed prior to full regulatory approval; however, the change shall not be
retumed to operation until complete and formal regulatory approval is required."
Using the Nuclear Documents (NUDOCS) system and references from the
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Comed Nuclear Tracking system, the inspector also reviewed Comed
commitments to the NRC. This review was made to determine whether use of
emergency modifications or at-risk work was contrary to any commitments that
Comed had made to the NRC such as corrective actions for past design and
design control problems. None were identified.
The inspector concluded that adequate allowances and controlling limitations for
development of emergency and immediate modifications were accounted for in the
Quad Cities QA Program and in corporate procedures,
b.2.
Quad Cities Use of Exoedited Design Process and Review of Site Procedures
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The three vehicles used at Quad Cities that could potentially bypass the design process
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were (1) emergency modifications, (2) at-risk work requests and (3) immediate
modifications.
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Emergency Modifications
Emergency modifications at Quad Cities were developed using the guidance of
Corporate Procedure NEP 04-01, " Plant Modifications," The inspector observed that the
word " emergency" was not defined and use of emergency modifications was at the
discretion of plant management. However, emergency modifications were infrequently
used and their use to expedite the schedule during the Fall 1997 recent Appendix R
compliance issues was not considered unreasonable. The inspector did not review the
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overall Appendix R effort or other aspects related to the safe shutdown analysis, but did
review a sample of design packages for content, hold points and other limitations and
did not identify any design process deviations for emergency modifications.
At-Risk Work
At Quad Cities, development of at-risk work packages was done under the auspices of
procedure QCAP 2200-02," Action Request / Work Request Initiation." The licensee
defined at-risk work as work completed at " commercial risk" prior to all work control
documents being approved. The work can be performed at the Plant Manager's
discretion after analyzing the risk. Per the procedure, the work would be done only on
components that are inoperable and the design documentation must be completed pnot
to returning the component to service. The PlF process would be used as an available
mechanism to control at-risk work to ensure that the inoperable compor ants were not
declared operable prior to completion of all design documentation. Adctionally,
Attachment C of the procedure would be completed to describe the wock description,
justification for the work, and discussion of the commercial risk involved
The inspector determined that implementation of the at-risk work package option had
been infrequent. Based on interviews, the inspector also noted that the licensee
wrestled with whether to use at-risk work requests during the Appendix R modifications
and ultimately decided to use the at-risk option for fabrication and procurement only and
not for installation. This decision stemmed from the Appendix R modification that routed
cable trays along the power block. Installation of anchor bolts on concrete walls on an
at-risk basis was contemplated since the design package was not completed. Internal
debate among licensee staff resulted in a decision to wait for the modification package
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to be complete in lieu commencing installation. This was due to the fact that the
concrete wall was not conducive to being declared inoperable. The licensee concluded
that the at-risk process could not readily be used on walls or other components or
systems that were not readily isolatable or could not be readily declared inoperable.
Subsequently, for Appendix R related components or structures, use of at-risk work
packages was confined to at-risk fabrication and at-risk procurement and not
installations.
A sample review of these packages and interviews with licensee staff indicated that for
at-risk work packages, the work analyst, the design engineer and the construction staff
worked in unison and the at-risk work packages were not generated or installed in a
" vacuum " The inspector noted that for at-risk work completed, there was minimal
likelihood the installation work would not be approved or qualified or would change
during the approval process. For example, the inspector reviewed in detail Work
Package 970104149-03 which replaced the 3/4" recirculation loop sample valve,
AO-2-0220-44, under at-risk conditions. Primarily due to lack of vendor seismic report
information, the package was generated and installed between October 6 through 10,
1997 in parallel with development of the design modification package, DCN 001581M,
which was approved on October 14,1997.
The inspector observed that the details for preparation and control of at-risk work
packages did not change from regular work packages. The work analysts continued to
use the precautions and limitations of procedure QCAP 2200-04," Preparation and
Control of Work Packages," during development of the at-risk work packages.
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Additionally, precautions and limitations, design considerations, QC hold points, test
requirements, technical reviews and structures, systems and component boundaries
were appropriately handled.
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Use of at-risk work packages was first allowed in 1996 by Revision 8 of QCAP 2200-02,
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" Action Request / Work Request Initiation." As discussed above, with the components
declared inoperable, at-risk work was not considered contrary to Comed QA
requirements. The inspector noted that upon implementation of the at-risk option at
Quad Cities, the licensee did not revise all applicable design change procedures.
Specifically, QCAP 0460-01, " Plant Design Change Process," Step D.4.a continued to
require that the installer receive an aooroved design change package prior to work
package preparation. Development of at-risk work was, therefore, contrary to
QCAP 0460-01. The at-risk work package reviewed in detail, Work Package
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970104149-03, was considered a procedural adherence violation contrary to 10 CFR 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings" (VIO 50-254/98005-
01; 50-265/98005-01(DRS)).
Immediate Modifications
Designation of a modification as an "immediate" modification was a third vehicle used to
expedite design changes. These modifications were not " emergency" modifications but
rather full modifications that would not be presented to the Technical Review
Board (TRB)/ Site Planning Group (SPG) until up to one month after initiation instead of
prior to the start of the modification development. This bypass required approval by the
Site Vice President and was primarily an administrative bypass since "immediate"
modifications would still get an On-Site review prior to issuance of the MAL. Use of the
"immediate" modification option was also not common and use was limited to instances
where the normal TRB/SPG approval process would create unacceptable delay in
processing the change. "Immediate" modifications appeared adequately controlled and
proceduralized including a requirement for generation of a PIF as a mechanism for
documenting the urgency and to ensure TRB/SPG review occurs within one month. The
inspector did not identify any regulatory commitment or requirement specifying that the
TRB/SPG review occur prior to modification development.
c.
Conclusion
Allowances, with precautions, for development of emergency and immediate
modifications were adequately accounted for in the Quad Cities QA Program and in
corporate and station procedures. Use of these types of modifications was not common
and, when used, adequate controls existed to ensure minimum prerequisites, limitations,
and operational restrictions were considered, including cornpletion of 10 CFR 50.59
screenings or safety evaluations.
Adequate controls were in place to ensure that components would not be declared
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operable until completion of the all design documentation when at-risk work packages
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were developed in parallel with the design packages. Use of the at-risk process was not
routine and work completed appeared well-coordinated between the work analyst,
design and construction staff. While generation of at-risk work packages was allowed
by the Work Request Initiation procedure, at-risk work was contrary to the Plant Design
Change Process procedure. This was considered a procedural adherence violation.
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E8
Miscellaneous Engineering issues
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E8.1
(Closed) Unresolved item (URI 50-254/94004-16: 50-265/94004-16): Review of
evaluations of piping with potential to leak over safety related switchgear. The inspector
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verified that the licensee completed a series of walkdowns of susceptible switchgear and
verified that susceptible floor slab piping penetrations were adequately sealed. The
licensee walkdowns also revealed heating lines that appeared to require additional
supports. To address this, the licensee added supports in one case and, in another
case, a stress analysis was generated to demonstrate that additional supports were not
needed. This item is closed.
E8.2 (Closed) Insoection Followuo item (IFl 50-254/94004-29: 50-265/94004-29): High
Emergency Diesel Generator Cooling Water (EDGCW) pump flow evaluation did not
consider negative effects on EDGCW Heat Exchangers. In response, the licensee
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contacted the EDG vendor and satisfactorily evaluated the higher flow conditions to
conclude that the observed higher flows (1680 gpm vs. a baseline of 1500 gpm) were
acceptable. High flows were noted again in January 1995 when the Unit 1 EDGCW
pump quarterly flow rate test indicated that the pump was performing in a region beyond
the analyzed pump curve. These high flows were attributed to a throttle valve that was
incorrectly positioned as wide open. The inspector reviewed licensee procedure
changes to ensure positive controls on the throttle valve position were implemented.
Also reviewed were the last four Unit 1 quarterly flow rate tests that confirmed that the
pump was consistently operating within the acceptance criteria. This item is closed.
E8.3 (Closed) Unresolved item (URI 50-254/94004-32: 50-265/94004-321: RHR Containment
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Isolation Valve not seat leak tested. The inspector reviewed the licensee scope and test
acceptance criteria for the IST and Appendix J programs. IST acceptance criteria for
stroke time and position indication and recent test data was satisfactory. The inspector
confirmed that the RHR 1(2)-1001-28 A, B valves were sealed with a qualified seal
water system. The inspector also confirmed that the RHR 1(2) 1001-07 A, B, C, D
pump suction valves were located on a line below the minimum suppression pool level
ensuring a potential pathway would be water-filled post-accident. Thus it was
acceptable to exclude the valves from LLRT testing. This item is closed.
E8.4 (Closed) Insoection Followuo item (IFl 50-254/94004-44: 50-265/94004-44):
Inadequate Prioritization, Trending and Status Control of the Site Engineering Service
Requests (SESR) Process. The inspector noted that SESRs are now part of the
Integrated Quality Report (lOE). lOE monthly performance review reports were
reviewed by the inspector who confirmed that on a monthly basis, the site satisfactorily
tracks and trends open, overdue, and the average age of open SESRs. Weekly reports
of overdue SESRs were printed with IQE color coded windows highlighting the number
of overdue SESRs. Prioritization was appropriately addressed via the Engineering
Request screening committee. This item is closed.
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E8.6 (Closed) Insoection Followuo item (IFl 50-254/94004-49: 50-265/94004-49): Corporate
Engineering Support Weaknesses. The licensee had initiated several improvement
efforts and management changes to address corporate engineering support
weaknesses, such as peer group reviews, Integrated Strategic Planning and
development of the Management Review Board. Improvements had occurred in the
interface between corporate and site personnel, with a primary example being the
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ongoing effort expended in resolution of the Appendix R issue. However,
comprehensive and effective resolution of deficiencies identified by the Vulnerability
Assessment Team, the Diagnostic Evaluation Team, and the QC Course of Action
(COA) continued to be a concern. These deficiencies were discussed in the Licensee's
letter to the NRC dated January 2,1998 (SVP 98-002). Efforts to determine why
actions taken were not fully effective in providing a framework for longer term
continuous improvements were under licensee review. These efforts will be evaluated
as part of the core program using inspection Procedure 37550. This item is closed.
E8.7a (Closed) Violation (VIO 50-254/94020-03a: 50-265/94020-03a): Failure to correct RHR
2B minimum flow check valve after failed IST test. The inspector confirmed that, after
check valve refurbishment, the subsequent IST and operability tests were successful.
Further the inspector confirmed that the licensee's Restart Checklist was implemented
to ensure that open corrective maintenance work requests were reviewed for potential
impact on unit startup and power operations. This item is closed.
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E8.7b (Closed) Violation (VIO 50-254/94020-03b: 50-265/94020-03b): Inadequate corrective
actions with Stand By Liquid Control (SBLC) system relief valves'setpoint drift problem.
The inspector reviewed actions taken to minimize setpoint drift including: cessation of
system flushing prior to checking the setpoint, installation of heat tracing on the relief
valves to address crystallization in the valve internals, trending of test results and failure
events, and bench testing of the relief valves in lieu of testing on the system. Based on
the testing and trending data, other actions to further minimize setpoint drift were still
contemplated. However, the inspector concluded that actions taken were satisfactorily
addressing and minimizing the setpoint drift. This item is closed.
E8.7c (Closed) Violation (VIO 50-254/94020-03c: 50-265/94020-03c): Administrative closure
of PlF resulting in failure to evaluate and correct RCIC rupture disc flange and seating
surface . The inspector reviewed the actions taken in response to the violation and
noted that since the 1994 violation an siectronic PlF system had been implemented
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which should facilitate communication of PlFs' status to all departments and minimize
similar administrative closures. The inspector also observed that for this violation, the
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administrative closure of the Level IV PlF did not prevent the implementation of
corrective actions. An evaluation was completed to address the potential condensate
accumulation on the RCIC turbine and rupture disc which satisfactorily concluded that
the condensate collected would not significantly impact the turbine or rupture disc
functionality. The RCIC rupture disks and pipe flanges were replaced for both units.
Additionally, the Unit 1 RCIC steam exhaust piping was inspected and a similar concern
was not identified. This item is closed
E8.8 (Closed) Violation (VIO 50-254/94020-04a. b: 50-265/94020-04a.b): Two examples of
10 CFR 50.55a(f)(4)(ii) violations (ASME IST Requirements). In the first example, the
licensee's failure to adequately test the SBLC system pumps' 1 A and 28 discharge
check valve was satisfactorily addressed by disassembling and inspecting the valves.
The check valves were replaced with a spring-loaded check valve design. The inspector
observed that the closed function test method of the check valves had been revised and
the test procedures had also been satisfactorily revised. The valves were no v tested by
establishing a vent path upstream of the applicable check valve while operating the
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other loop's pump and monitoring the change in its flow rate. Further, the inspector
confirmed that the last surveillance tests for each unit were satisfactory. This item is
closed.
In the second example of this violation, the licensee had failed to adequately exercise
the core spray minimum flow check valves to the full stroke position required to fulfill
their safety function. The inspector noted that the initial test method had been
reclassified as a partial open test and the IST program revision of May 15,1995,
satisfactorily addressed the full flow test disassembly and inspection. The inspector
observed that testing and inspection to date was acceptable. This item is closed.
V. Management Meetings
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Exit Meeting Summary
The inspector presented the inspection results to members of licensee management at the
conclusion of the inspection on March 26,1998. The licensee acknowledged the findings
presented.
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PARTIAL LIST OF PERSONS CONTACTED
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Licensee
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C. Peterson
Regulatory Assurance Manager
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M. Fiumadore
Design Engineering
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B. Weaver
Work Analyst- Mechanical
R. Bozarth
Modification Coordinator
M. Sullivan
Construction Supervisor
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INSPECTION PROCEDURES USED
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Engineering
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On-Site Engineering
Design, Design Changes, and Modifications
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Facility Modifications
Design Changes and Modification Program
Follow-up - Engineering
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ITEMS OPENED, CLOSED, AND DISCUSSED
Ooened
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50-254/98005-01
proc violation work package prepared prior to design
approval
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Closed
50-254/94004-16
pipe leaks over switchgear evaluation program
50-265/94004-10
50-254/94004-29
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EDGCW pump flow not evaluated
50-265/94004-29
50-254/94004-32
RHR valves not seat leak tested
50-265/94004-32
50-254/94004-44
IFl
SESR process inadequately statused
50-265/94004-44
50-254/94004-49
IFl
corp engineering support weaknesses
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50-265/94004-49
50-254/94020-03a,b,c;
3 examples of corrective action violation
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50-265/94020-03a,b,c
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50-254/94020-04a,b
2 examples of 50.55a (ASME IST) requirements violation
50-265/94020-04a,b
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LIST OF ACRONYMS AND INITIALISMS USED
American Society of Mechanical Engineers
CFR
Code of Federal Regulations
Comed
Commonwealth Edison Company
COA
Course of Action
DCN
Design Change Notice
Diesel Generator
Division of Reactor Safety
EDGCWP
Diesel Generator Cooling Water Pump
IFl
Inspection Follow-up Item
lOE
Integrated Quality Report
In-Service Testing
Local Leak Rate Test
MAL
Modification Approval Letter
NTS
Nuclear Tracking System
Public Document Room
PlF
Problem Identification Form
Quality Assurance
OCAP
Quad Cities Administrative Procedure
Reactor Core isolation Cooling
SBLC
SESR
Site Engineering Service Request
TRB/SPG
Technical Review Board / Site Planning Group
Unresolved item
Violation
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